Foundation Says Most Support Spectrum for Neuromuscular Microstimulators
The Alfred Mann Foundation urged the FCC to take quick action on its proposal for a 20 MHz allocation in the 413-457 MHz band for wirelessly connecting neuromuscular microstimulators implanted in patients who suffer from brain and spinal cord injuries and neuromuscular disorders. In March, the commission approved rules to set up a new Medical Device Radiocommunication Service in the 401-402 and 405-406 MHz bands, and also sought comment on the AMF proposal for a medical micropower network allocation.
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“The parties supporting MMN rules represent a broad spectrum of interests, including Congressional leaders, government agencies, veterans organizations, medical research and treatment establishments, non-profit organizations, private industry (including equipment manufacturers and pharmaceutical companies), doctors, scientists, and individuals with disabilities,” the foundation said in reply comments. “Even the few parties opposing the Commission’s proposal concede that MMNs offer invaluable public interest benefits.”
The foundation said that contrary to the handful of objections, “both the Commission and the scientific community have found the 413-457 MHz band to be within the narrow range of spectrum that is most suitable for radiofrequency signal propagation within the human body.” AMF also said initial human trials using MMN devices are expected to start next year: “The ultimate success of these trials will depend largely upon the regulatory certainty that only the Commission can provide.”
“The AMF innovation holds exceptional therapeutic promise previously unattainable for millions of Americans, including U.S. military service personnel and veterans, living with sensory and motor dysfunction due to injury or disease,” said Paralyzed Veterans of America. “We know that such promise will not be realized unless the Commission provides critical access to sufficient spectrum and establishes a minimum set of rules to facilitate co-existence among wireless systems.”
But the Society of Broadcast Engineers said it agreed with objections raised by the Association of Public-Safety Communications Officials, the Land Mobile Communications Council and the Association for Maximum Service Television that the proposal is “flawed” and would “subject MMN device users to harmful, and perhaps dangerous, interference from much higher power co-channel signals.” The objection is especially true for the 451-457 MHz allotment, which would share spectrum with 455-456 MHz Part 74 subpart D remote pickup stations, SBE said.
The Enterprise Wireless Alliance said the FCC has already created the Wireless Medical Telemetry Service, which may be suitable for the use AMF proposed. “It is incumbent on the AMF, as the proponent of this proposal, to demonstrate with far greater specificity than has been provided to date why these already allocated bands cannot be used for this particular purpose based on technical requirements, rather than cost of devices or convenience in development,” the alliance said. Also, the commission does not have enough evidence that the MMN systems wouldn’t cause interference to incumbent users of the 413-457 MHz band.